IRCCourt RulingsJul 11, 2024
…ty Benefit
The “ Form 1099 – SSA ” to which the 2015 NOD refers as reporting
a distribution of $24, 708 is clearly in reference to Mrs. Tuma’s 2015
Form SSA – 1099 , which reported a Social Security benefit of that
amount. Th e $24 , 708 amount is also consistent with Mrs. Tuma’s RRB
benefit letter . The letter provide…
IRCCourt RulingsOct 10, 2018
…deem this
issue to have been waived or conceded.
- 18 -
of petitioners' nontax expenses would be $4,708 (($8751 - $1,828) × 0.68), rather
than $4,580 (as the letter calculated). Taking these adjustments into account, the
April 4, 2012, letter should have calculated a monthly payment amount of $5,537
(i.e., $4,708 (proj…
IRCCourt RulingsJan 9, 1985★ strong match
… on the dates shown was as follows:
Bate Balance
8/31/78 $123,727.08
8/31/79 131,211.18
8/31/80 141,708.07
8/31/81 144,502.33
4/ 9/84 131,432.30 Added to the Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, section 4975 imposes two levels of …
IRCCourt RulingsJul 24, 1991related by meaning
Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute.
II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
IRCCourt RulingsAug 3, 1979related by meaning
istinguishing our opinion in that case, and we see none. On the basis of Orzechowski, we hold that the section 4973 tax applies in docket No. 9115-77. The notices of deficiency addressed to the petitioners in docket No. 9115-77 did not set forth separately the asserted deficiencies in individual income taxes and the as…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…es. He estimated total engineering costs,
including grading and other lot improvements , at $17,121,708, or
approximately $305,745 per lot. He also opined that it would take one
year to obtain clearances necessary to record final maps and that this
process could overlap with the coastal development permit request
proce…
84 FR 20801 — User Fees Relating to Enrolled Agents and Enrolled Retirement Plan Agents IRCFinal Rules (FR)May 13, 2019
sts
$4,561,280,779
Direct Labor and Benefits Costs
÷ $6,708,063,559
Corporate Overhead Rate
68.00%
5. Calculation of the per Unit Cost of the User Fee The IRS used projections for fiscal years 2018 through 2020 to determine the direct costs associated with enrolled agent enrollment and renewal and enrolled retirement p…
IRCCourt RulingsJan 29, 2019
…ed to reimbursement from his employer for such expenses. See
Fountain v. Commissioner, 59 T.C. 696, 708 (1973). The taxpayer can prove that
he is not entitled to reimbursement by showing, for example, that he is expected to
bear these costs. See id. at 708. An expense for which the taxpayer is entitled to
(but does not…
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
IRCCourt RulingsFeb 24, 2016
…tion from Mr. McGaugh's individual retirement account ("IRA") and an
accuracy-related penalty of $2,708 under section 6662(a). The matter is currently
before the Court on Mr. McGaugh's motion for summary judgment pursuant to
Rule 121, which the Commissioner has opposed.
The issue for decision is whether a transaction i…
IRCCourt RulingsMay 9, 1988related by meaning
e reasons stated herein, respondent former trustees’ motion to dismiss for lack of jurisdiction will be granted.
An appropriate order will be entered. These cases were assigned pursuant to sec. 7456 (redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rule 180. All s…
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…er statements = 6,004,514 frozen DB Statements × 3.9% delivered by paper
1
1.05
245,885
374,708,891
On top of this baseline burden, SECURE 2.0 and associated proposal will add costs due to the provision of additional paper benefit statements. The costs associated with providing the additional paper benefit stat…
IRCCourt RulingsSep 24, 2007related by meaning
)(2) addition to tax . The sec .
6651(a)(2) addition to tax was listed only in the Form 4549,
Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that
respondent raised the sec . 6651(a)(2) addition to tax in his
answer, albeit while misciting that sectio…
89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…The Department assumes RCH will combine these notices as a cost savings measure, resulting in 6,117,708 fewer notices needing to be prepared and sent over the 10-year period. The cost savings is calculated as -6,117,708 notices × 2/60 hours to prepare each notice on average × $63.45 wage rate for clerical staff = −$12,…
IRCCourt RulingsAug 12, 1980related by meaning
nstant case — to avoid the section 4973 excise tax.
We hold that Johnson is liable for the asserted excise taxes under section 4973 for 1975 and 1976. It appears that the notice of deficiency addressed to petitioners may be understood as asserting joint liabilities for the excise tax deficiencies. (See n.l supra) Since…
IRCCourt RulingsFeb 10, 1997related by meaning
ith respect to our Opinion.
In our Opinion, we held that petitioner may not deduct in a
single taxable year contributions to 29 collectively bargained defined benefit plans made over a period of 20 (in some cases 19)
months. In the Motion petitioner alleges that the Court erred in
that this holding contradicts 20 years…
83 FR 58202 — User Fees Relating to Enrolled Agents and Enrolled Retirement Plan Agents IRCProposed Rules (FR)Proposed Nov 19, 2018
…olled agent enrollment and renewal and enrolled retirement plan agent renewal is projected to be $2,708,603 in total over fiscal years 2018 through 2020. The labor and benefits costs include the cost to perform background checks and tax compliance checks, which are services that were not included in the previous $30 us…